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Nurse Practitioners Sue the State of California Over Right to Use ‘Doctor’ in Titles

Charmaine Robinson, MSN-Ed, BSN, RN
Updated September 19, 2023
Edited by
    Should doctoral-prepared nurse practitioners be referred to as “doctors''? Learn about the California lawsuit that’s stirring the debate.
    Nurses and doctors looking over a file togetherCredit: Getty Images
    • There are legal consequences for non-physician practitioners who use “doctor” to identify themselves.
    • Three doctoral-prepared nurse practitioners sued the state of California for the right to call themselves doctors based on their degree of study.
    • Physicians and nurse practitioners share varying opinions on the debate, including when to make exceptions to the rule.

    Some may argue that the medical field has monopolized the term “doctor.” Physicians are doctors of medicine, just as judges are doctors of law. Should doctoral-prepared nurse practitioners (NPs) refer to themselves as doctors if they are doctors of nursing practice?

    This pressing question in the most recent doctor-nurse rivalry debate. Explore state laws regarding NPs using the title and varying opinions on the matter.

    Why Three NPs in California Are Suing the State

    Three NPs in California sued the state for the right to use “doctor” in their titles, according to a July 2023 report in the Washington Post.

    Jacqueline Palmer, a doctoral-prepared NP, admitted to introducing herself as a doctor to her patients but stated that she would describe her nursing education and explain to them that she was not a physician. However, after hearing about Sarah Erny — a California doctoral-prepared NP who was fined almost $20,000 by the state for referring to herself as a doctor on social media and professional websites — Palmer decided to take legal action to protect herself.

    Palmer and two other doctoral-prepared NPs sued the California attorney general and leaders of the Medical Board of California and California Board of Registered Nursing for the right to call themselves doctors.

    Even though she eventually asked her patients to stop calling her “doctor,” Palmer asserted that using the title was not based on an ego trip.

    [My patients] all have said that they know that I worked hard for it…They know that I’m a nurse practitioner; there was no misconception.”

    The explanation may not be enough to protect NPs who refer to themselves as doctors, as California is among several states that place legal limitations on the use of medical titles.

    Use of Doctor in Title in California and Other States

    With patient care at the forefront, are titles really worth “doctoring” up a debate over? Several states tend to think so.

    California law states that only graduates of medical school and those with a license to practice medicine are legally permitted to use “doctor” or “physician”‘ and the prefix “Dr.” or initials “M.D.” Anyone who does not fit these qualifications and uses these terms in a sign, business card, letterhead, or advertisement is guilty of a misdemeanor.

    Georgia recently enacted a law preventing non-physician clinicians with doctoral degrees (i.e., advanced practice nurses and physician assistants) from identifying themselves as doctors. The law requires that healthcare practitioners clearly list the licenses under which they are permitted to practice on all forms of verbal, written, or electronic advertisements.

    “This new law makes it clearer for patients to make informed decisions because they know the qualifications of the professional providing their care,” said Michael W. Champeau, M.D., FAAP, FASA, president of the American Society of Anesthesiologists, in a statement.

    Indiana enacted a similar law in 2022 focusing on the inappropriate use of medical specialty titles by non-physician clinicians (i.e., nurse anesthesiologists).

    While many agree with the states’ legislative acts, some believe the title “doctor” may be used under certain circumstances. As the debate continues, physicians and nurse practitioners have chimed in with varying opinions.

    Should Nurse Practitioners with Doctoral Degrees Be Called ‘Doctors’?

    Doctoral degrees can be obtained in various fields, from arts and sciences to business and law. Some may argue that the term “doctor” should refer to the level of education received. However, the real concern seems to be whether NPs should use the term when interacting with patients.

    Jacqueline Miller, DNP, FNP-C, an endocrinology nurse practitioner, believes that doctoral-prepared NPs should be able to use the doctor title in clinical settings.

    “…Nurse Practitioners that earn a doctorate in nursing practice deserve to use the title ‘doctor’ in a clinical setting in spite of the controversial views perceived by their colleagues,” she said.

    For some, the clinical setting is the basis for their opposing argument.

    Gary Gaddis, M.D., Ph.D., clinical professor of emergency medicine at Washington University School of Medicine in St. Louis, believes that advanced practice nurses with a DNP should refrain from referring to themselves as doctors in a clinical setting.

    “In an academic setting, they could appropriately ask to be called ‘doctor.’ But, to call themselves ‘doctor’ in a clinical setting misleads the patient and perpetrates a fraud which defies their patient’s trust,” Gaddis wrote in Missouri Medicine.

    Gaddis argued that a significant knowledge and training gap exists between physicians and non-physicians or advanced nurse practitioners (ANPs).

    “ANP programs provide their students with much less in-depth instruction in both the pre-clinical medical sciences, such as anatomy and physiology, and the clinical medical sciences, such as pharmacology or clinical pathology, than do schools of medicine or osteopathy.”

    Patients may not understand this difference.

    Miller believes that using the term “doctor” while interacting with patients may lead to confusion if not expounded upon.

    […] however, I believe it is appropriate to use doctor in your title in a clinical setting if patients clearly understand that you are an advanced nurse practitioner with a doctorate rather than a practicing physician.”

    Throughout history, “doctor” has been reserved for the medical physician. Unraveling society’s perception of the word may not necessarily be a priority. The consensus among many healthcare professionals is that patients should not be misled.

    Meet Our Contributor

    Portrait of Jacqueline Miller, DNP, FNP-C

    Jacqueline Miller, DNP, FNP-C

    Jacqueline Miller, DNP, FNP-C graduated from Texas Tech University Health Science Center with a post-master’s certification as a family nurse practitioner in 2019 and a doctorate in nursing practice in 2020. Miller currently works as an endocrinology nurse practitioner.